As the Legislature printed it
DIVISION 4. WORKERS' COMPENSATION AND INSURANCE [3200 - 6002] · PART 2. COMPUTATION OF COMPENSATION [4451 - 4856] · CHAPTER 2. Compensation Schedules [4550 - 4856] · ARTICLE 2.5. Medical-Legal Expenses [4620 - 4628]
(a) In accordance with the rules of practice and procedure of the appeals board, the employee, or the dependents of a deceased employee, shall be reimbursed for his or her medical-legal expenses and reasonably, actually, and necessarily incurred, except as provided in Section 4064. The reasonableness of, and necessity for, incurring these expenses shall be determined with respect to the time when the expenses were actually incurred. Costs for medical evaluations, diagnostic tests, and interpreters’ services incidental to the production of a medical report shall not be incurred earlier than the date of receipt by the employer, the employer’s insurance carrier, or, if represented, the attorney of record, of all reports and documents required by the administrative director incidental to the services. This subdivision is not applicable unless there has been compliance with Section 4620. (b) Except as provided in subdivision (c) and Sections 4061 and 4062, no comprehensive medical-legal evaluations, except those at the request of an employer, shall be performed during the first 60 days after the notice of claim has been filed pursuant to Section 5401, and neither the employer nor the employee shall be liable for any expenses incurred for comprehensive medical-legal evaluations performed within the first 60 days after the notice of claim has been filed pursuant to Section 5401. (c) Comprehensive medical-legal evaluations may be performed at any time after the claim form has been filed pursuant to Section 5401 if the employer has rejected the claim. (d) Where, at the request of the employer, the employer’s insurance carrier, the administrative director, the appeals board, or a referee, the employee submits to examination by a physician, he or she shall be entitled to receive, in addition to all other benefits herein provided, all reasonable expenses of transportation, meals, and lodging incident to reporting for the examination to the same extent and manner as provided for in Section 4600.
How panels applied this section
Newest released decisions whose legal-standard extraction named this section. Each quotes the passage and links to the official PDF. Unofficial guide — not legal advice.
- ADJ8866704 · 2026-06-29 · Los Angeles District Office§ 4621
Determinative passage · p.4II. Pursuant to Colamonico v. Secure Transportation (2019) 84 Cal.Comp.Cases 1059 (Appeals Board en banc), a lien claimant holds the initial burden of proof pursuant under sections 4620 and 4621: that a contested claim existed at the time the expenses were incurred, that the expenses were incurred for the purpose of proving or disproving a contested claim, and that its services were reasonably, actually, and necessarily incurred. We stated that: Section 4620(a) defines a medical-legal expense as a cost or expense that a party incurs "for the purpose of proving or disproving a contested claim." (§ 4620(a).) Copy service fees are considered medical-legal expenses under section 4620(a). (Citations) Lien claimant's initial burden in proving entitlement to reimbursement for a medical-legal expense is to show that a "contested claim" existed at the time the service was performed. Subsection (b) sets forth the parameters for determining whether a contested claim existed. (§ 4620(b).) Essentially, there is a contested claim when: 1) the employer knows or reasonably should know of an employee's claim for workers' compensation benefits; and 2) the employer denies the
The Appeals Board applied this standard to find that the cost petitioner met its burden to prove a contested claim existed at the time the services were rendered.
Official decision · page 4 → - ADJ11186589 · 2026-06-18 · Los Angeles District Office§ 4621
Determinative passage · p.5In the present matter, the WCJ found that lien claimant failed to establish any basis for reimbursement for the lien claim filed in this matter. We disagree. Here, the issue of whether lien claimant was entitled to payment for medical-legal costs was not an issue raised at trial. In the Petition for Reconsideration, lien claimant raises the issue because the WCJ found that it was not entitled to any payment.
Applied to defer issue of payment for medical-legal expenses pending adjudication of contested claim elements.
Official decision · page 5 → - ADJ8710590 · 2026-05-26 · Riverside District Office§ 4621
Determinative passage · p.7A cost petitioner holds the burden of proof to establish all elements necessary to establish its entitlement to payment for a medical-legal expense. (See § 3205.5, 5705.5; Torres v. AJC Sandblasting (2012) 77 Cal.Comp.Cases 1113, 1115 (Appeals Board en banc).) As we explained in our en banc decision in Colamonico v. Secure Transportation (2019) 84 Cal.Comp.Cases 1059 (Appeals Board en banc), section 4622 provides the framework for reimbursement of medical-
Cost petitioner met burden to show contested claim existed and services were reasonable and necessary; defendant failed to timely object with compliant Explanation of Review; cost petitioner entitled to reimbursement, penalties, and interest.
Official decision · page 7 → - ADJ7404188 · 2026-03-02 · Long Beach Office District Office§ 4621
Determinative passage · p.6A cost petitioner holds the burden of proof to establish all elements necessary to establish its entitlement to payment for a medical-legal expense. (See § 3205.5, 5705.5; Torres v. AJC Sandblasting (2012) 77 Cal.Comp.Cases 1113, 1115 (Appeals Board en banc).) As we explained in our en banc decision in Colamonico v. Secure Transportation (2019) 84 Cal.Comp.Cases 1059 (Appeals Board en banc), section 4622 provides the framework for reimbursement of medical- legal expenses. Subsection (f) of the statute, however, specifically states that "[t]his section is not applicable unless there has been compliance with Sections 4620 and 4621." (Lab. Code, § 4622(f).)
The WCAB applied this standard to find that the cost petitioner met its burden to show a contested claim existed at the time the medical-legal copy services were provided.
Official decision · page 6 → - ADJ11777176 · 2026-02-11 · Stockton District Office§ 4621
Determinative passage · p.3Whether a medical-legal expense is compensable depends on whether the expense is "reasonably, actually, and necessarily incurred". (§ 4621.) While a primary treater may request authorization for diagnostic testing, such a request is not generally subject to utilization review, but instead is simply seeking defendant's agreement that the medical-legal expense is reasonable before it is provided. Here, the primary treater provided medical-legal services in connection with an examination that defendant expressly authorized. All of the medical-legal services provided appear reasonable.
The Board found the lien claimant's diagnostic testing and examination reasonable and necessary, thus compensable.
Official decision · page 3 → - ADJ10790437 · 2026-02-09 · Riverside District Office§ 4621
Determinative passage · p.7A lien claimant holds the burden of proof to establish all elements necessary to establish its entitlement to payment for a medical-legal expense. (See Lab Code, § 3205.5, 5705; Torres v. AJC Sandblasting (2012) 77 Cal.Comp.Cases 1113, 1115 [2012 Cal. Wrk. Comp. LEXIS 160] (Appeals Board en banc).) Thus, a lien claimant is required to establish that: 1) a contested claim existed at the time the expenses were incurred; 2) the expenses were incurred for the purpose of proving or disproving the contested claim; and 3) the expenses were reasonable and necessary at the time they were incurred. (Lab. Code, § 4620, 4621, 4622(f); American Psycometric Consultants Inc. v. Workers' Comp. Appeals Bd. (Hurtado) (1995) 36 Cal.App.4th 1626 [60 Cal.Comp.Cases 559].) Pursuant to Colamonico v. Secure Transportation (2019) 84
Applied to determine whether lien claimant met burden for medical-legal expenses.
Official decision · page 7 → - ADJ9935791 · 2025-12-15 · Van Nuys District Office§ 4621
Determinative passage · p.4A lien claimant holds the burden of proof to establish all elements necessary to establish its entitlement to payment for a medical-legal expense. (See Lab. Code, § 3205.5, 5705.5; Torres v. AJC Sandblasting (2012) 77 Cal.Comp.Cases 1113, 1115 (Appeals Board en banc).) As we explained in our en banc decision in Colamonico v. Secure Transportation (2019) 84 Cal. Comp. Cases 1059 (Appeals Board en banc), Labor Code section 46222 provides the framework for reimbursement of medical-legal expenses. Subsection (f) of the statute, however, specifically states that "[t]his section is not applicable unless there has been compliance with Sections 4620 and 4621." (Lab. Code, § 4622(f).) Thus, a lien claimant is required to establish that: 1) a contested claim existed at the time the expenses were incurred; 2) the expenses were incurred for the purpose of proving or disproving the contested claim; and 3) the expenses were reasonable and necessary at the time were incurred. (Lab. Code, § 4620, 4621, 4622(f); Colamonico, supra, 84 Cal.Comp.Cases 1059.)
Lien claimant must show contested claim existed when expenses were incurred and that expenses were reasonable and necessary.
Official decision · page 4 → - ADJ8236211 · 2025-10-24 · Riverside District Office§ 4621
Determinative passage · p.6A cost petitioner holds the burden of proof to establish all elements necessary to establish its entitlement to payment for a medical-legal expense. (See § 3205.5, 5705.5; Torres v. AJC Sandblasting (2012) 77 Cal.Comp.Cases 1113, 1115 (Appeals Board en banc).) As we explained in our en banc decision in Colamonico v. Secure Transportation (2019) 84 Cal.Comp.Cases 1059 (Appeals Board en banc), section 4622 provides the framework for reimbursement of medical-legal expenses. Subsection (f) of the statute, however, specifically states that "[t]his section is not applicable unless there has been compliance with Sections 4620 and 4621." (§ 4622(f).)
Applied to determine burden of proof for medical-legal expense reimbursement.
Official decision · page 6 →
All 35 decisions naming § 4621 →
The rules written under this section
A statute says what is owed; Title 8 says by when, on what form, and what happens if the deadline passes. These name § 4621as what they implement.
- 8 CCR § 10101Claim File--Contents.
- 8 CCR § 10101.1Claim File--Contents.
- 8 CCR § 10102Retention of Claim Files.
- 8 CCR § 10108Audit Violations--General Rules.
- 8 CCR § 10110Notice of Intention to Issue a Notice of Compensation Due; Notice of Compensation Due; Review by Workers' Compensation Appeals Board.
- 8 CCR § 10111Schedule of Administrative Penalties for injuries on or after January 1, 1990, but before January 1, 1994.
- 8 CCR § 10111.1Schedule of Administrative Penalties for Injuries on or After January 1, 1994.
- 8 CCR § 10111.2Full Compliance Audit Penalty Schedules; Target Audit Penalty Schedule.
- 8 CCR § 10451.1Determination of Medical-Legal Expense Disputes. [Repealed]repealed
- 8 CCR § 10564Interpreters. [Renumbered]repealed
- 8 CCR § 10647Witness Fees and Subpoenas.
- 8 CCR § 10790Interpreters.
Also on this
Unofficial guide — not legal advice. The statute is the state’s text. The quotes are litigated applications, not a prediction.
About California Labor Code § 4621
What is California Labor Code § 4621?
Labor Code § 4621 sits in ARTICLE 2.5. Medical-Legal Expenses [4620 - 4628]. The statute on this page begins: (a) In accordance with the rules of practice and procedure of the appeals board, the employee, or the dependents of a deceased employee. The official display is on LegInfo; this is a reprint.
Did WCAB panels apply Labor Code § 4621 in this corpus?
This corpus has 35 released decisions whose extracted legal standards named § 4621. Quotes and PDFs are on this page. That is not every case in California that ever cited the section.